Texas Underground Injection Control Program 2018 TCEQ Environmental Conference & Trade Fair May 16, 2018 Lorrie Council, P.G., Manager, UIC Permits Section Radioactive Materials Division Office of Waste Image Group is TCEQ Logo and Diagram of Class I Injection Wells

TCEQ UIC Organization UIC Program Implemented by: Office of Waste, Radioactive Materials Division (RMD): Permitting & Authorizations Class I Well Construction Oversight/Approval Well Plugging Oversight/Approval Office of Compliance & Enforcement: Workover Approvals Mechanical Integrity Test Oversight Routine Operations & Reporting EPA Compliance Related Reporting Compliance & Enforcement UIC Class I & III Permitting for In-Situ Uranium Facilities Conducted by RMD’s Radioactive Materials Section RMD’s UIC Permits Section Focus: Application Review & Permitting for Class I & V Wells UIC Programmatic Reporting & Coordination with EPA UIC Rulemaking & Legislative Bill Analysis UIC Program Coordination Image Group is TCEQ Logo and Diagram of Class  I Injection Wells

TCEQ UIC Staff Updates Staffing challenges continue – 2 vacancies currently open in RMD/UIC Lean staffing requires streamlining of processes & prioritizing assignments UIC Permits Section Staffing Changes: Kathryn Hoffman, PE, UIC Engineer, retired May 2017 Carol Dye, PG, UIC Geologist, transferred to UIC July 2017 (formerly in Uranium Group) Tom Ortiz, PE, UIC Engineer, resigned July 2017 (vacant position) Andy Trevino, PE, UIC Engineer, joined November 2017 Radioactive Materials Section Staffing Changes: Maryann Ryan, PG, Uranium Licensing & Permitting Geologist, retired October 2017 (vacant position)

TCEQ UIC Inventory by Well Class A table lists numbers of TCEQ-regulated UIC facilities and wells, as reported by TCEQ to EPA in February 2018, broken down by class of injection well

UIC Class I Permit Applications & Permits Issued in 2017 Class I Applications Received Class I Permits Issued New Permit 3 Permit Renewal 5 12 Permit Renewal/Major Amend 1 Permit Renewal/Minor Amend Major Amendment Minor Amendment 13 17 Minor Modification 10 Endorsement 8 Transfer PIU Registration New/Renewal A table depicts Class 1 applications by type as compared to the Class 1 permits issued for that type, for 2017.

Class I Highlights TCEQ is processing new Class I permit applications for two facilities: New industrial facility in Calhoun Co. (two additional, deeper hazardous waste disposal wells); Commercial non-hazardous waste disposal well in Jack Co. currently permitted as a Class II commercial oil & gas disposal well. Several Class I renewal, amendment, & minor modification applications were completed in 2017 or are in process (in final notice period). UIC Permits Staff worked with permittees on reservoir pressure & operating pressure monitoring for atypical situations in east Texas & the Texas Panhandle, including downhole injection pressure monitoring

Class I Wells Installed Since 2010 Class I Well Permit No. Facility Location Construction Approval Date WDW398 Houston 8/13/2010 WDW419 Duval County 12/8/2010 WDW408 Freeport 12/22/2010 WDW332 Sunray 10/25/2011 WDW299 Texas City 11/18/2011 WDW317 Dayton 12/20/2012 WDW432 Amarillo 3/14/2014 WDW351 Borger 2/23/2016 WDWG010001 San Antonio 3/9/2016 WDWG010002 WDW435 Report under review WDW436 WDW450 Marshall 3/8/2017 WDW391 Beaumont Report not submitted WDW335 Cactus 4/21/2017 WDW279 Robstown 2/5/2018 Image Group is Diagram of Class I Injection Wells

Class I Wells Closed Since 2010 Class I Well Permit No. Facility Location Closure Approval Date WDW151 Duval County 1/15/2010 WDW299 Texas City 11/18/2011 WDW111 Houston 5/24/2013 WDW016 Odessa 7/11/2013 WDW401 Cleburne 11/5/2015 WDW125 Beaumont 12/22/2015 WDW036 Channelview 2/4/2016 WDW180 Marshall 3/18/2016 WDW243 WDW091 2/2/2017 WDW196 WDW314 WDW395 Winnie 6/6/2017 Image Group is Diagram of Class I Injection Wells

UIC Class III Applications & Permits Issued in 2017 Class III Applications Received Class III Permits Issued New Area Permit Area Permit Renewal 1 Permit Renewal/Major Amend Major Amendment Permit or PAA Minor Amend 3 Permit or PAA Minor Mod Endorsement Transfer A table lists Class three applications by type compared to class three permits by each respective type, for calendar year 2017.

Class III Highlights The low pricing of uranium yellow cake continues to affect the uranium industry. TCEQ’s permitting workload for in-situ uranium mines mirrors the industry slowdown. Texas Mining & Reclamation Association submitted a rule petition to TCEQ in October 2016. UIC-related revisions requested include changes to rules for in-situ uranium mining The Commission will consider publishing proposed new rules June 27, 2018 The Commission will consider adopting proposed new rules November 14, 2018 Image Group is uranium yellowcake

UIC Class V Authorizations 2017 Class V Well Type Number of Authorizations or Amendments Issued Number of Associated Wells Aquifer Recharge Wells 5R21 (includes ASR Wells) 2 1 WWTP Disposal 5W12 Septic System/Drain Field Disposal Method 5W32 Experimental Wells 5X25 3 Aquifer Remediation 5X26 75 1,907 (includes temporary injection points) Other Wells 5X27 Total 83 1,914 A table lists the number of Authorizations and Amendments along with the number of associated wells for each type of class five well in 2017.

Class V: Aquifer Storage & Recovery (ASR) Wells TCEQ adopted revised rules in response to HB655 on Aquifer Storage & Recovery (ASR) Wells May 2016. During 2017, TCEQ issued two authorizations for ASR-related experimental wells: City of Victoria - large scale cycle testing Ruby Ranch Water Company - small scale cycle testing In 2017, TCEQ issued an authorization for a recharge well to inject stormwater captured from a residential rooftop in NW Austin. Because the site is not in a groundwater conservation district & there are no expectations of recovering the injected water, it was considered to be a recharge well. TCEQ is developing guidance documents for ASR project applications, focusing on methods to determine recoverability of injected water.

Class V: Experimental Wells Experimental wells include a broad range of wells used for testing, such as: aquifer dye tracing, CO2 sequestration, ASR recoverability & formation properties testing. In 2011, TCEQ issued an authorization for a deep experimental well to obtain reservoir properties data evaluate the viability of disposing water treatment residuals from a proposed clean power plant. Well was installed to ~7,350 feet below ground surface & tested in 2012. In 2017, the operator filed for Ch. 7 Bankruptcy before the well was plugged. TCEQ is working with AG’s Office with the goal of plugging the well.

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Questions? Lorrie Council, P.G., Manager, UIC Permits Section Texas Commission on Environmental Quality lorrie.council@tceq.texas.gov (512) 239-6461 Main RMD/UIC Phone: 512-239-6466 http://www.tceq.texas.gov http://www.tceq.texas.gov/permitting/waste_permits/uic_permits/uic.html